As we reported last week, the DOL has delayed enforcement of the 2013 round of 404a-5 participant fee disclosures for six months. The analysts at Relius have released two helpful follow-on resources — a technical update taking a deeper dive into the implications of the 404a-5 enforcement delay and a brief FAQ on the status of the 408b-2 service provider disclosures. The FAQs include:
• What’s the deadline for providing the 408b-2 disclosures?
• Are disclosures required annually?
• Does the 404a-5 extension affect the 408b-2 disclosures?
